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For the purposes of subsection 129(3) … the "dividend refund" means the amount equal to the lesser of the amounts set out in subparagraphs 129(1)(a)(i) and (ii). Consequently … the amount of Portfolioco's RDTOH account for its 1998 taxation year would be reduced by the $100,000 dividend refund that would have been made by the CCRA had Portfolioco filed its return of income in accordance with paragraph 150(1)(a). ...

In the case of an agent … the fees paid by the professional should be reasonable and correspond to the fair market value of the services rendered by the agent. Furthermore, if it were a genuine management company and not an agent of the professional, the CCRA would question the deductibility of the … fee if the management company had no employees to perform the functions for which the professional was billed. ...

. … [T]he reassessments would be attributable to FAPI arising directly from the contribution by the Taxpayer of the Marketable Securities to ForeignCo which … would be a "transaction" between Holdco and ForeignCo referred to in subparagraph 152(4)(b)(iii) that it would be reasonable to consider as relating to the reassessments for purposes of subparagraph 152(4.01)(b)(iii). ...

After referencing the requirement in s. 147.2(2)(a)(vi), which “ensures that any unfunded liability associated with a participating employer, and thus the employer’s contributions in respect of that liability, are not excessive,” and the s. 147.2(2)(d) requirement that “there is a reasonable determination of each participating employer’s actuarial surplus,” CRA stated that in such situation: [T]he particular employer would nonetheless continue to be considered a participating employer …. ... This helps avoid problems that could arise from experience gains or losses. … This position applies regardless of whether the particular employer ceases to exist, except where specific rules provide otherwise. ...

In 2017-0735771I7, Headquarters rejected this position on the basis that, for purposes of s. 40(3.5)(c)(i), Bco was a corporation “formed” on the “merger” of CCo with BCo – with the result that BCo was deemed to continue to own the shares of CCo with which it was affiliated, notwithstanding that CCo had, in fact, ceased to exist. ... Headquarters concluded that this resulted in the loss being de-suspended, stating: Upon the completion of the liquidation of BCo, it would no longer be affiliated with ACo. … Pursuant to subparagraph 40(3.4)(b)(i), the Suspended Loss will be deemed to be a capital loss of ACo immediately after the completion of the liquidation of BCo. ...

. … If the[re] is considered to be one failure, the taxpayer would only be liable to a maximum penalty of $100 under subsection 162(5) for failing to provide information. ... In our view, such an approach would “discourage taxpayers from being diligent and taking reasonable care in the preparation of their returns.” … [W]e suggest that care be taken to ensure that assessing penalties under subsections 162(5) and (7) is both appropriate based on the relevant facts of a situation and equitable to the tax community as a whole. ...

This is a question of fact …. Similarly, in other situations where an eligible entity pays an amount that is rent for the use of, or the right to use, an area or space that is a portion of a larger area, the amount paid by the eligible entity as rent may be a qualifying rent expense …. ...

Regarding the deductibility of amounts paid after the time of the order, the Directorate stated: [W]here the lump-sum amount is paid pursuant to a court order that establishes a clear obligation to pay retroactive periodic maintenance for a specified period prior to the date of the court order … the lump-sum payment will not, in and of itself, change the nature of the underlying legal obligation of periodic maintenance payments and, if all other requirements are met, the lump-sum amount paid will be deductible to the payer according to the formula in paragraph 60(b) …. ...

. … [Here] paragraphs 161(7)(a) and (b) of the Act do not apply and assuming that the non-capital losses are sufficient to completely offset the increase in income, the taxpayer’s taxable income will not change. … Consequently, the tax calculation will not change, and there will be no arrears interest charged on the reassessment. ...

The Directorate found that if the tokens were held in a business on income account: [A] deposit of the Deposited Tokens, redemption of the Receipt Tokens, and sale of the Receipt Tokens for goods constitute barter transactions in accordance with … IT-490. ... Similarly, if the taxpayer sold the Receipt Tokens in exchange for money, the realization principle should typically apply such that the transaction is a taxable event …. ...